Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 90
Page 6
... entitled to challenge " the existence or amount of the underlying tax liability ” if he or she " did not receive any statutory notice of 9 Neither party originally argued that this case was moot as to petitioner's taxable year 1992 ...
... entitled to challenge " the existence or amount of the underlying tax liability ” if he or she " did not receive any statutory notice of 9 Neither party originally argued that this case was moot as to petitioner's taxable year 1992 ...
Page 7
... entitled under section 6330 " . Id . Similarly , in Gerakios v . Commissioner , T.C. Memo . 2004-203 , we dis- missed the collection review proceeding as moot where the parties agreed that there was no unpaid liability upon which a lien ...
... entitled under section 6330 " . Id . Similarly , in Gerakios v . Commissioner , T.C. Memo . 2004-203 , we dis- missed the collection review proceeding as moot where the parties agreed that there was no unpaid liability upon which a lien ...
Page 8
... entitled to a refund for : all compound interest she paid for the period April 15 , 1993 to July 18 , 2000 , all interest she paid for periods during which interest was suspended or [ sic ] July 5 , 1997 to July 3 , 2000 ; and for all ...
... entitled to a refund for : all compound interest she paid for the period April 15 , 1993 to July 18 , 2000 , all interest she paid for periods during which interest was suspended or [ sic ] July 5 , 1997 to July 3 , 2000 ; and for all ...
Page 11
... entitled . " ) . In sum , given that explicit statutory authority was required before this Court acquired jurisdiction to determine overpayments in deficiency cases , and given that additional explicit statutory authority was required ...
... entitled . " ) . In sum , given that explicit statutory authority was required before this Court acquired jurisdiction to determine overpayments in deficiency cases , and given that additional explicit statutory authority was required ...
Page 12
... entitled to refunds . By contrast , section 6330 incorporates no such limitations on the allowance of tax refunds or credits . There is no indica- tion that in enacting section 6330 , Congress intended , sub silentio , to provide ...
... entitled to refunds . By contrast , section 6330 incorporates no such limitations on the allowance of tax refunds or credits . There is no indica- tion that in enacting section 6330 , Congress intended , sub silentio , to provide ...
Contents
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Common terms and phrases
9th Cir adjustments Admin administrative affd amended amount Anglo-Am Antarctica Appeals officer apply assessment Brand X capital loss Chevron claim closing agreement coal Commis Commissioner community property laws computation Congress conservation easement Court of Appeals December 31 deficiency notice Direct Tea Trading disputed regulations election entitled Fairfax County Federal income tax Federal tax foreign corporation GATT rate Grist Mill property gross income hearing Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service interpretation issue jurisdiction Lee Ranch legislative history levy LIFO limited majority mark-to-market ment method of accounting Natl notice of determination ous payment 99.00 overpayment interest parties petition petitioner petitioner's Planegger Proced provides real property reasonable refund relevant text relief Rept request respondent respondent's Revenue Act rule Secretary section 233 sioner spouse Stat statute statutory Subsequent miscellane supply contracts supra T.C. Memo Tax Court tax lien taxpayer tion United Zapara